Non-discrimination clause in tax treaties – Select issues and recent developments – Part 3

In part 2 of the series, I have discussed Article 24(1) which deals with Nationality non-discrimination in detail. In this part, I will discuss Article 24(2) dealing with stateless person

As mentioned earlier, Paragraph 2 of Article 24 of the OECD model convention extends the benefit of non-discrimination clause to stateless person who are residents of one of the contracting states.

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The views in all sections are personal views of the author.